In January 2009, the FCC released a public notice soliciting comment on its
proposed 70/70 reporting form requiring the submission of certain information for 2006
and 2007 (“New Requirements”).1 In developing these proposed New Requirements,
the FCC grossly underestimated the burden of collecting the data on small and mediumsized
cable operators. Moreover, these proposed New Requirements, if imposed,
would violate the Paperwork Reduction Act (“PRA”) and the OMB’s regulations2
because the FCC did not make an effort to reduce the burden of the requirements for
small business concerns.

Accordingly, absent changes to the proposed form,3 the American Cable
Association (“ACA”) requests that the OMB disapprove the New Requirements.